Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Disallowance of commission expenses - Once the sample size has been selected by the AO and which has been accepted by the ld CIT(A), the findings on examination of such sample size should be correlated and could reasonably be held representative only proportionality and not of the whole data under examination. In the instant case, basis the sample size of less than 1% which remains unverified, it is incorrect to hold that 100% of claim of commission expenditure remains unsubstantiated
Disallowance of commission expenses - Once the sample size has been selected by the AO and which has been accepted by the ld CIT(A), the findings on examination of such sample size should be correlated and could reasonably be held representative only proportionality and not of the whole data under examination. In the instant case, basis the sample size of less than 1% which remains unverified, it is incorrect to hold that 100% of claim of commission expenditure remains unsubstantiated
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